Supreme Court Dismisses Revenue SLP as Tax Effect Below CBDT Threshold Lacks Legal Exception Supreme Court Dismisses Revenue SLP as Tax Effect Below CBDT Threshold Lacks Legal Exception Issue Whether a Special Leave Petition (SLP) filed by the Revenue is maintainable under Section 268A when the monetary tax effect is below the prescribed CBDT limit… Read More »
Supreme Court Dismisses Revenue’s SLP as Withdrawn, Upholding That Section 14A Requires Actual Exempt Income Supreme Court Dismisses Revenue’s SLP as Withdrawn, Upholding That Section 14A Requires Actual Exempt Income Issue Whether Section 14A of the Income-tax Act, 1961 (corresponding to Section 14 of the Income-tax Act, 2025) can be invoked to disallow expenditure when… Read More »
Supreme Court Dismisses Revenue SLP Affirming High Court Ruling Favouring Insurance Assessee Across Issues Supreme Court Dismisses Revenue SLP Affirming High Court Ruling Favouring Insurance Assessee Across Issues Issues Applicability of Disallowance Under Section 14A: Whether Section 14A applies to the computation of profits and gains of general insurance businesses under Section 44 read with… Read More »
Tribunal Order Deleting Addition Set Aside as Finding on Delayed Retraction and Denial of Cross-Examination Was Perverse Issue Whether the Tribunal was justified in deleting an assessment addition on grounds of statement retraction and denial of cross-examination when the retraction occurred two years later as an afterthought and no request for cross-examination was ever made… Read More »
Denial of Opportunity to Cross-Examine Official Authors and Examine Buyers’ Witnesses Violates Principles of Natural Justice Issue Whether the rejection of an assessee’s request to cross-examine official reporting officers and the refusal to record statements of buyer witnesses produced by the assessee during reassessment proceedings under Section 69A read with Section 148 constitutes a violation… Read More »
Reopening Reassessment Solely to Verify Bank Cash Deposits Without Tangible Material Is Without Jurisdiction Issue Whether the Assessing Officer can validly initiate reassessment proceedings under Section 147/148 solely to verify the source of cash deposits in an assessee’s bank account, without possessing independent tangible material to form a belief that income chargeable to tax has… Read More »
Orders Issued Electronically Without Initial DIN Are Valid If Subsequently Communicated With Correct DIN Issue Whether DRP directions and revisional orders under Section 263 initially communicated electronically without a Document Identification Number (DIN)—or containing a minor typographical error in the manually written DIN—are invalid under CBDT Circular No. 19/2019, when DINs were later generated and… Read More »
Reassessment Under Section 147 Based on Search Material Is Void as Section 153C Provisions Apply Exclusively Reassessment Under Section 147 Based on Search Material Is Void as Section 153C Provisions Apply Exclusively Issue Whether the Assessing Officer has jurisdiction to initiate reassessment proceedings under Section 147/148 based on material seized during a Section 132 search… Read More »
Section 263 revision setting aside assessment solely to direct Section 270A penalty initiation is legally unsustainable. Issue Whether the PCIT can invoke Section 263 of the Income-tax Act, 1961 / Section 377 of the Income-tax Act, 2025 to set aside an assessment order solely for directing the Assessing Officer to initiate discretionary penalty proceedings under… Read More »
Reassessment notice issued beyond three years without PCCIT approval under Section 151 is invalid Issue Whether a notice issued under Section 148 after the expiry of three years from the end of the relevant assessment year without obtaining approval from the specified authority under Section 151 is valid, and whether the consequent reassessment order under… Read More »